NonSub Change - SSN in Follow-ups

To: Kelsi Feltz

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Marie Lawrence, Sarita Barton, and Megan Reid

Office of Planning, Research, and Evaluation (OPRE)

Administration for Children and Families (ACF)

Date: August 6, 2024

Subject: NonSubstantive Change Request – Next Generation of Enhanced Employment Strategies Project (OMB #0970-0545)

This memo requests approval of nonsubstantive changes to the approved information collection, Next Generation of Enhanced Employment Strategies Project (OMB #0970-0545).

Background

Information collection for the Next Generation of Enhanced Employment Strategies (NextGen) Project was originally approved in April 2020 and granted a three-year extension in April 2023. Approval covered 11 data collection instruments including a baseline survey, identifying and contact information, two follow-up participant surveys, service receipt tracking, program and staff surveys, program and employer discussion guides, an in-depth participant interview, and a cost workbook. Currently, the NextGen Project has completed study enrollment and is fielding both the first and second follow-up surveys (Instruments 3 and 4) with NextGen study participants across four programs.

The project is submitting this nonsubstantive change request in order to address missing Social Security numbers from some study participants. As approved, the project attempted to collect Social Security numbers from study participants during the enrollment process. Having study participants’ Social Security numbers allows the project to collect administrative records necessary for the impact analysis. Specifically, the project team uses participants’ Social Security numbers to gather administrative records that may include:

• Quarterly earnings, receipt of unemployment insurance, and new hires from the National Directory of New Hires (NDNH), which is maintained by the Office of Child Support Services at ACF.

• Available records for study participants on the receipt of Temporary Assistance for Needy Families (TANF) from program data and contact information from state or local TANF agencies.

• Administrative data from the Social Security Administration on annual taxable earnings and receipt of Supplemental Security Income (SSI) and Social Security Disability Insurance (SSDI).

• Receipt of Supplemental Nutrition Assistance Program (SNAP) benefits and contact information.

• Receipt of benefits and contact information from the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC).

• State records on child support owed or paid.

• Health care outcomes (Medicare enrollment and claims) from the Centers for Medicare & Medicaid Services.

• Involvement with the criminal justice system from court records.

• Educational attainment and completion from school districts.

• Receipt of housing benefits (such as participation in a housing choice voucher program) from housing authorities.

As of May 2024, 216 study participants (about 6.5 percent) did not provide Social Security numbers during enrollment. These missing cases effectively reduce the sample size for any analysis involving administrative records. The sample size reduction lowers the statistical power of the study’s administrative data and will increase the minimum detectable differences between program and control groups.

Overview of Requested Changes

The project team seeks approval to add a question to both the first and second follow-up surveys (Instruments 3 and 4) to ask for a NextGen Project participant’s Social Security number if they did not provide it upon study enrollment. The project team already requests Social Security numbers from study participants during the study enrollment process using the approved identifying and contact information data collection (Instrument 2), which has gone out for public comment multiple times between initial and revision requests that included public comment periods (no comments were received related to the request for numbers). Collecting this information will ensure that the project team can conduct analysis on administrative data records for a larger percentage of the study sample.

This request includes updated Instruments 3 and 4, as well as Appendix D (question-by-question justification for follow-up surveys), with these revisions.

This nonsubstantive change request does not impact the average burden per response for any of the data collection activities.

Time Sensitivities

Since data collection is in process, we request a response as soon as possible.